RC Update!
May 10 2018 | Washington, D.C.

RAD Novogradac Conference 

The RAD Collaborative and CLPHA were pleased to serve as strategic sponsors to the Novogradac-organized RAD Public Housing Conference in Philadelphia on April 26-27. The day-and-a half session addressed a range of RAD matters of interest to both those new to RAD and those transforming their PHAs into conventional Section 8-LIHTC owners-developers-managers and resident services coordinators. Click here to see the conference agenda and access many helpful presentations.

As the regional convening in Philadelphia proved a productive forum, please stay tuned for dates and details on the next Collaborative-sponsored regional convening this summer in the Midwest.

Using RAD's New Authorities

The most recent RAD, LIHTC and Section 18 Demo/Dispo developments in Washington were also discussed. At the conference and in further conversations with the Collaborative, Tom Davis of HUD’s Recap Office outlined what’s to come next in implementing these new authorities. Recap is:

  • Devising a Federal Register notice for publication in the next 30-45 days—and possibly even sooner—to spell out how the increase in the RAD public housing cap to 455,000 units will be handled and how rents will be set for newly-issued CHAPs, to permit higher rent levels in Rent Supp and RAP conversions in high cost markets, and to implement Component 2 resident rescreening provisions which were included in the Omnibus.
  • Amending the application form for those on the RAD waiting list submitting full applications, and for future applications.
  • Drafting a supplemental RAD notice, also for publication in the next 30-45 days, to make a few discrete changes in the RAD notice, potentially addressing policy objectives related to homelessness, the use of RAD together with agency Project-Based Vouchers and other items.
  • Intending to issue a more thorough RAD Revision 4 Notice in early Fall 2018 to address the new authority to convert Section 202 PRAC properties under RAD, changes to the Mod Rehab component of RAD, how the new cap and new 2024 sunset may affect RAD milestones and monitoring procedures, and additional modifications to the public housing conversion processes.
  • Anticipating that HUD will issue guidance in the next few weeks on how recent revisions to the Section 18 Demo/Dispo Notice will be implemented, including the new “75/25” provision for combining RAD and Section 18-generated Tenant Protection Vouchers, and dispositions of scattered-site units and for PHAs with less than 50 public housing units in their inventory.
  • Anticipating HUD to work on a revised Section 3 rule, reflecting the Secretary’s interest in promoting economic opportunity for residents of HUD-assisted housing.
New LIHTC & Opportunity Zones Benefits

A number of panelists at the Novogradac RAD conference also addressed how changes in appropriations bill for both LIHTCs and the new Opportunity Zones can enhance RAD’s implementation, including LIHTC income-averaging and combining housing tax credits with new Opportunity Zones benefits could boost investments in RAD projects. For more information on the both the new LIHTC and Opportunity Zones provisions, click on the Novogradac links below:

As additional information on any and all of these promising provisions becomes available, the Collaborative will work with HUD and others in various forums to review key elements with practitioners.

GAO RAD Report

In late March, GAO issued a report on RAD’s public housing implementation to date, undertaken at the request of Ranking Member Maxine Waters of the House Financial Services Committee. Among other findings and recommendations, the report encouraged HUD to enhance efforts to monitor and assure tenants’ rights under the program and prepare to ensure RAD’s long-term affordability in the event of potential foreclosures when private debt is used. It also questioned including the amount of private equity investment generated from LIHTCs in calculating RAD’s leverage estimates. A copy of the full GAO report can be found here, including HUD’s observations at the end of the report.

HUD has endorsed GAO’s basic recommendations. Tom Davis of the Recap Office offered perspectives on the report along with some other varied criticisms of RAD’s progress in a recent article in The Intercept.    

Practice News & Notes




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